190502-13959

CourtBoard of Veterans' Appeals
DecidedAugust 31, 2020
Docket190502-13959
StatusUnpublished

This text of 190502-13959 (190502-13959) is published on Counsel Stack Legal Research, covering Board of Veterans' Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
190502-13959, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 08/31/20 Archive Date: 08/31/20

DOCKET NO. 190502-13959 DATE: August 31, 2020

ORDER

Entitlement to a rating in excess of 10 percent for status post right foot fractures with mild hallux valgus deformity and hammer toes is denied.

Entitlement to a rating in excess of 10 percent for status post left foot fractures with mild hallux valgus deformity and hammer toes is denied.

Entitlement to a separate 10 percent rating for metatarsalgia is granted.

FINDINGS OF FACT

1. Throughout the appeal period, the Veteran has been in receipt of the maximum schedular rating authorized under Diagnostic Code (DC) 5280 for right hallux valgus and hammer toes.

2. Throughout the appeal period, the Veteran has been in receipt of the maximum schedular rating authorized under DC 5280 for left hallux valgus and hammer toes.

3. The April 2017 VA examination documented the diagnosis of metatarsalgia in both feet.

CONCLUSIONS OF LAW

1. The criteria for a rating in excess of 10 percent for hallux valgus and hammer toes, right foot, have not been met. 38 U.S.C. § 1155, 5107(b); 38 C.F.R. § 4.71a, DC 5280.

2. The criteria for a rating in excess of 10 percent for hallux valgus and hammer toes, left foot, have not been met. 38 U.S.C. § 1155, 5107(b); 38 C.F.R. § 4.71a, DC 5280.

3. With resolution of reasonable doubt in the Veteran’s favor, the criteria for a separate rating of 10 percent for bilateral metatarsalgia, have been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.10, 4.40, 4.45, 4.59, 4.71a, DC 5279.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty from October 1998 to February 1999.

On August 23, 2017, the President signed into law the Veterans Appeals Improvement and Modernization Act, Pub. L. No. 115-55 (to be codified as amended in scattered sections of 38 U.S.C.), 131 Stat. 1105 (2017), also known as the Appeals Modernization Act (AMA). This law, which will go into effect in February 2019, creates a new framework for Veterans dissatisfied with VA’s decision on their claim to seek review.

In August 2018, VA received notice that the Veteran chose to participate in VA’s test program, the Rapid Appeals Modernization Program (RAMP). The Board is honoring her choice and, accordingly, this decision has been written consistent with the new AMA framework.

The Veteran selected the Higher-Level Review lane when she submitted the RAMP election form. Accordingly, the January 2019 RAMP rating decision considered the evidence as of the date VA received the RAMP election form. She timely appealed this RAMP rating decision to the Board and selected Direct Review. Direct review is the appeal option to the Board in which a Board decision is issued based on evidence of record at the time of the prior decision. The Board cannot hold a hearing or accept into the record additional evidence in its direct review.

Increase Rating

A disability rating is determined by the application of VA’s Schedule for Rating Disabilities (Rating Schedule), 38 C.F.R. Part 4. The percentage ratings contained in the Rating Schedule represent, as far as can be practicably determined, the average impairment in earning capacity resulting from diseases and injuries incurred or aggravated during military service and their residual conditions in civil occupations. Separate DCs identify the various disabilities. 38 U.S.C. § 1155; 38 C.F.R. § 4.1.

Where there is a question as to which of two evaluations shall be applied, the higher evaluation will be assigned if the disability picture more nearly approximates the criteria for that rating. Otherwise, the lower rating will be assigned. 38 C.F.R. § 4.7.

The Board will consider whether separate ratings may be assigned for separate periods of time based on facts found, a practice known as “staged ratings,” whether it is an initial rating case or not. Fenderson v. West, 12 Vet. App. 119, 126-27 (1999); Hart v. Mansfield, 21 Vet. App. 505 (2007).

The Veteran is competent to testify on factual matters of which he has first-hand knowledge. Washington v. Nicholson, 19 Vet. App. 362 (2005). He is also competent to report symptoms of his right and left foot disabilities. Layno v. Brown, 6 Vet. App. 465, 469-71 (1994). The Veteran is competent to describe his symptoms and their effects on employment or daily activities.

Disability of the musculoskeletal system is primarily the inability, due to damage or infection in parts of the system, to perform the normal working movements of the body with normal excursion, strength, speed, coordination, and endurance. 38 C.F.R. § 4.40. Functional loss may be due to pain, supported by adequate pathology and evidenced by the visible behavior in undertaking the motion. 38 C.F.R. § 4.59 (discussing facial expressions such as wincing, muscle spasm, crepitation, etc.). Weakness is as important as limitation of motion, and a part that becomes painful on use must be regarded as seriously disabled. Excess fatigability and incoordination should be considered in addition to more movement than normal, less movement than normal, and weakened movement. 38 C.F.R. § 4.45.

The intent of the schedule is to recognize painful motion with joint or periarticular pathology as productive of disability. It is the intention to recognize actually painful, unstable, or malaligned joints, due to healed injury, as entitled to at least the minimum compensable rating for the joint. See 38 C.F.R. § 4.59. Although the first sentence of 38 C.F.R. § 4.59 refers only to arthritis, the regulation applies to joint conditions other than arthritis. Burton v. Shinseki, 25 Vet. App. 1, 3-5 (2011).

In evaluating disabilities of the musculoskeletal system, it is necessary to consider, along with the schedular criteria, functional loss due to flare-ups of pain, fatigability, incoordination, pain on movement, and weakness. DeLuca v. Brown, 8 Vet. App. 202 (1995).

Although pain may cause functional loss, pain itself does not constitute functional loss. Rather, pain must affect some aspect of “the normal working movements of the body,” such as “excursion, strength, speed, coordination, and endurance,” in order to constitute functional loss. Mitchell v. Shinseki, 25 Vet. App. 32, 38-43 (2011) (quoting 38 C.F.R.

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Related

Jandreau v. Nicholson
492 F.3d 1372 (Federal Circuit, 2007)
King v. Dept. Of Veterans Affairs
700 F.3d 1339 (Federal Circuit, 2012)
JAMES A. W ASHINGTON v. R. James Nicholson
19 Vet. App. 362 (Veterans Claims, 2005)
James P. Barr v. R. James Nicholson
21 Vet. App. 303 (Veterans Claims, 2007)
Brian J. Hart v. Gordon H. Mansfield
21 Vet. App. 505 (Veterans Claims, 2007)
Tyra K. Mitchell v. Eric K. Shinseki
25 Vet. App. 32 (Veterans Claims, 2011)
Russell W. Burton v. Eric K. Shinseki
25 Vet. App. 1 (Veterans Claims, 2011)
Ulysses Copeland v. Robert A. McDonald
27 Vet. App. 333 (Veterans Claims, 2015)
Layno v. Brown
6 Vet. App. 465 (Veterans Claims, 1994)
DeLuca v. Brown
8 Vet. App. 202 (Veterans Claims, 1995)
Johnson v. Brown
9 Vet. App. 7 (Veterans Claims, 1996)
Fenderson v. West
12 Vet. App. 119 (Veterans Claims, 1999)

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190502-13959, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190502-13959-bva-2020.